I have a few questions, if anyone is happen to share what they know it would be much appreciated. I have a few questions around the cost base of the EDV and WOW shares that I now currently own. You have the same number of parcels of EDV as you do WOW each with their own acquisition dates and costbases as per 1 & 2 above. one unit in Shopping Centres Australasia Property Retail Trust (SCA Property Retail Trust). You have the same number of 'parcels' of EDV as you do WOW each with their own . When you sold your Woolworths shares, this right remained as a separate capital gains tax asset. It was shocking, Cereal is really the unsung hero of breakfast. By accepting all cookies, you agree to our use of cookies to deliver and maintain our services and site, improve the quality of Reddit, personalize Reddit content and advertising, and measure the effectiveness of advertising. What does this all mean for tracking the performance re. Desa / kelurahan. Here's what Because Neville purchased his shares at different times for different prices, he must do a separate calculation for his parcel of 800 shares and his parcel of 200 shares. Dividend amount of 1,000 $0.14195442 = $141.95, Capital return amount of 1,000 $0.14598558 = $145.98, Capital proceeds of $1.6248918 ($1.6347 99.4%), Total capital gain $38.766 ($0.19383 200 units), Capital proceeds of $0.0098082 ($1.6347 0.6%), Total capital gain $0.234 ($0.00117 200 units), Less cost base of $23,000.00 + 100.00 = $23,100.00, Dividend amount of 2,000 $0.14195442 = $283.90, Capital return amount of 2,000 $0.14598558 = $291.97, Capital proceeds of 400 $1.4397 = $575.88, Capital gain on the sale of her Woolworths shares of $35,700, Capital gain on the ending of the right to receive stapled securities = $291.98, Less prior year net capital loss of $50.00 = $35,941.98, Stacey now applies the 50% CGT discount $35,941.98 50% = $17,970.99, SCA Property Retail Trust units = $1.4310618, SCA Property Management Trust units = $0.0086382. Assuming 148 is correct: Woolworths are paying a cash dividend of $0.62 per share = $91.76. Not applicable for transferor company or transferee company opting for concessional tax regime under Section 115BAA and Section 115BAB of the Act. As per the amendments in FA 2021, goodwill is not considered to be a part of block of assets and hence is not eligible for depreciation. Following the demerger, the Company will provide an ATO approved split to be used where you apportion your current Woolworths cost base between your Endeavour shares and your Woolworths shares. Generally, the company that merges or amalgamates is known as the amalgamating company or transferor company.The corporate identity of the transferor company ceases to exist post amalgamation.The company into which the amalgamating or transferor company merges or amalgamates is known as the amalgamated company or transferee company. 7 Comment: Woolworths and Endeavour demerger. The Act [69] with effect from 1 April 2018 has been amended to widen the scope of the term accumulated profits, which provides that in the hands of the amalgamated company, accumulated profits or loss shall be increased by the accumulated profits of the amalgamating company, whether capitalized or not, on the date of amalgamation. As part of the demerger, undertaking of the demerged company (which includes accumulated profits) is transferred to the resulting company entailing a reduction in its reserves. Section 47(vicc) read with Explanation 5 to Section 9(1)(i) of the Act. $1.6248918 for each SCA Property Retail Trust unit, and. It is a settled position that the pre-requisite to create a charge of income under the head capital gain is that there has to be a transfer of an asset. Determination of the cost base is of relevance to the shareholder for the purpose of subsequent sale of shares of the resulting company. When I went vegan and started paying more attention to what was in my food, peanut butter didnt escape my gaze. The franking tax offset will be automatically applied. If you had owned your Woolworths shares for more than 12months prior to the receipt of the distribution, you can now reduce the capital gain by the 50% CGT discount. Step 5: Because Stacey received more than 318 stapled securities (valued at more than $500) she was not offered the opportunity to sell them in the sale facility. This condition requires issuance of shares. Woolworths Endeavour Demerger. Woolworths shareholders will be entitled to receive one share in Endeavour Group for each Woolworths share held on Friday, 25 June 2021. Using the ruling apportionment (point 16 in the ruling) results in Cost base of EDV shares as 10000* 14.19% = $1419. Under the current structure, Woolworths holds an 85.4% share of Endeavour Group with the remaining 14.6% interest held by its long-term joint venture partner, Bruce Mathieson Group (BMG). Depreciation claim for past years Whether impacted? Woolworths Group is proud to have over 350,000 shareholders, the vast majority of whom are Australian retail investors. The restructure involved a distribution under which you received one stapled unit in Shopping Centres Australasia Property Group (SCA Property Group) for every five Woolworths shares you owned on 30November 2012 (Distribution). Import your trading history directly from your broker or provider, Import trades via your brokers trade confirmations, Download spreadsheet from Commsec, NAB trade and Westpac, Add a Macquarie Cash Management Account (CMA), Automatically generated dividends and adjustments, How Sharesight can help with completing your tax return, How Sharesight helps you handle Australian AMIT tax components, Changing the tax setting of your portfolio, Recreating a portfolio in a different tax residency, Editing or Deleting trades and adjustments, Confirming multiple and individual unconfirmed transactions, Move a custom investment to a listed or supported investment. D. Under Section 47 (vii), the provisions of Section 45 do not apply to a transfer in a demerger of a capital asset by the demerged company to a resulting company if the resulting company is an Indian company. if(MSFPhover) { MSFPnav7n=MSFPpreload("../_derived/up_cmp_Profile110_up.gif"); MSFPnav7h=MSFPpreload("../_derived/up_cmp_Profile110_up_a.gif"); } There is no exit charge in the distributing company. I started my day making at least ten flavors. A new provision has been introduced in the Act [55] which provides that difference between the consideration and prescribed fair market value [56] of property [57] received by any person is liable to be taxed as income from other sources in the hands of the recipient if they are acquired without consideration or for a consideration that is lower than the aggregate fair market value (provided aggregate fair market value of such propertiesexceeds consideration paid, if any, by more than INR50,000). (ii) Period of holding of shares received in resulting company. Elections must be made by 21 June. I'm trying to track the performance of my WOW and new EDV shares, partially to help with capital gains tax etc etc. Can anyone give any pointers?! It has been prepared without having regard to or taking into account any particular investors objectives, financial situation and/or needs. No capital gains tax arises to the shareholders as any gains are rolled over. Taxability of gains from remission of liability, Allowability of expenses on amalgamation or demerger, Carry forward of losses of transferor company, Actual cost, written-down value (WDV) and depreciation in respect of capital assets transferred, Actual cost in respect of stock-in-trade transferred, Tax in the hands of the transferee company under the head Income from other sources, Tax in the hands of the amalgamated or resulting company on issuance of shares, Disallowance under Section 43B of the Act. Section 72A(2) of the Act read with Rule 9C of the Income-tax Rules, 1962. You can be patient with this stock. In particular, the dependence on poker machines means that Endeavour will be off the buy list for some fund managers, while other existing holders will use the demerger to exit Endeavour now that they can. I read a NAB article which suggested that I would be deemed to have acquired the EDV shares on the same that I acquired the WOW shares. for disallowing depreciation pertaining to goodwill from the quantum of unabsorbed depreciation, the amount of unabsorbed depreciation need not be disturbed and should be allowed to be set-off in full. Is this something we are still waiting information on? You do not include the capital return amount as income anywhere in your tax return if you continued to own your Woolworths shares on 11December 2012 (distribution date). Woolworths announced an update on significant items that would affect its FY21 accounts. This value is apportioned 99.4% to the SCA Property Retail Trust unit and 0.6% to the SCA Property Management Trust unit, giving their separate cost base of: For tax purposes you acquired the stapled securities on 11December 2012. A general guide to the tax implications for Tabcorp shareholders of the Demerger is contained within Section 6 of the Demerger Booklet lodged with the ASX on 31 March 2022. On 2 August 2022, the Federal Court of Australia approved the settlement and Maurice Blackburn was appointed as Administrator of the Settlement . If consideration is received in any form other than shares of the resulting company or received partly in shares and partly in any other form then that shareholder will not be eligible to claim exemption under the provision of the Act [50] . The amendment provides that aforesaid condition shall not be considered as breached if the resulting company was to record the property / liabilities of the demerged company at a value different from the value at which they were recorded in the books of the demerged company, immediately prior to demerger, only to comply with the Indian Accounting Standards specified in Annexure to the Companies (Indian Accounting Standards) Rules, 2015. Shareholders will be asked to approve the demerger via a resolution at a general meeting on Friday 18 June. By comparison, Woolworths has seen its share price rise, if only slightly since 24 June, with the stock up about 1.6% in that period. Demerger means the transfer of one or more undertakings to any resulting company by a demerged company in pursuant to a scheme of arrangement that fulfils the following conditions: All the property and liability of the undertaking "immediately before demerger" becomes the property and liability of the resulting . one unit in Shopping Centres Australasia Property Management Trust (SCA Property Management Trust), and. Australian Taxation Office for the Commonwealth of Australia. The demerger was effective on 1-7-2021. But I am baffled. The controversy as to whether Goodwill of a business is an intangible asset eligible for depreciation was settled by the Honble Supreme Court (SC) in the case of Smifs Securities Ltd. The capital gains from such slum sales are to be . 5 - 'Demerger . If you wanted your stapled securities sold in the sale facility, you did not need to do anything. 8 Best Vegan Cereal Brands to Start Breakfast off Right! The Explanatory Memorandum appears to give the impression that depreciation claim for the past years should be allowed basis the SC decision in CIT v. Smifs Securities Ltd [2012] 348 ITR 302 (SC). It may be noted that the Delhi Tribunal in NIIT technologies [48] has taken a view that deduction for expenses incurred on demerger is not allowable to the resulting company but is allowed only to the demerged company. References in this Demerger Booklet to the "Sierra Rutile Board" or to "Sierra Rutile Directors" means the board or directors of Sierra Rutile immediately prior to implementation . Once depreciation has been claimed and allowed in respect of any previous ear, unless there is retrospective amendment, the depreciation already allowed cannot be subject to any change on account of any subsequent amendment. Because Stacey owned Woolworths shares on 30November 2012 she had a right to receive SCA Property Group stapled securities under the distribution. If you subsequently sell your Endeavour shares, then you may have to pay capital gains tax.One thing that will change is your cost base for your Woolworths shares. The same is given below: Where the accumulated business loss and unabsorbed depreciation are directly relatable to the demerged undertaking, Entire amount of directly relatable losses and unabsorbed depreciation is allowed to be carried forward in the hands of the resulting company, Where the accumulated business loss and unabsorbed depreciation are not directly relatable to the demerged undertaking, Accumulated business loss and unabsorbed depreciation should be apportioned between the resulting company and the demerged company in the ratio of the assets transferred to the resulting company and assets retained by the demerged company. are incurred for giving effect to the scheme of demerger. If you are eligible to claim a franking tax offset for 201213 but you are not otherwise required to lodge a tax return, see Refund of franking credits instructions and application for individuals 2013. The resulting demerger will create two independent ASX-listed companies with . But with many brokers charging low minimums, in 2021, this is not that big a deal. SKOL Breweries Ltd v. ACIT [2008] 28ITATINDIA998 (Mum). The only advantage of doing this is the saving on brokerage which on a tiny parcel of shares, could be considerable. Pouring buckets of cream into ice cream makers, decorating it with chunky handfuls of toppings, and finally rippling in sugary sauces. 123,080 jiwa (2.001) jiwa. This is clearly marked. Neville has to work out the capital gain on the separate unit in SCA Property Retail Trust and SCA Property Management Trust that made up each stapled security. the dividend amount and franking credit attached to it. Then click on the 'Tax consequences' tab at the bottom of the spreadsheet to view the income tax consequences of the demerger.